Australian Privacy Policy

In carrying out our business, it may be necessary for us to collect personal information from clients, residents, customers, employees, contractors and other individuals. The type of personal information that may be collected will be determined by the nature of our business relationship with the individual.

This document sets out our policy for the collection, use, disclosure and storage of personal information that is covered under the Australian Privacy Act 1988 (Cth), as amended from time to time (the Act). We may, from time to time, amend and update this policy and publish the updated policy on our website.

General information about privacy and the operation of the Act can be found at the Office of the Australian Information Commissioner (OAIC) website at www.oaic.gov.au/privacy/about-privacy.

Definitions

In this policy, unless the context provides otherwise:

“electronic means” is a reference to any communication by online means, such as email, interaction via our website or via social media channels, such as Facebook, Twitter and YouTube;

“we“, “us” or “our” is a reference to Campus Living Villages Pty Limited ABN 19 093 198 915 and/or its related bodies corporate and related entities in relation to its operations in Australia (as applicable). Our contact details are on page 4 of this policy;

our social media accounts, which includes each Villages’ Facebook and Twitter accounts; and

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any ancillary portals provided through our websites, such as the Resident Portal or the Investor Portal which are accessible only by a unique username and password issued by us (or on our behalf) to you;

“Owner” is the owner entity or entities of the relevant Village;

“personal information” has the meaning given to that expression in the Act, which is a reference to information, or an opinion, about an individual that identifies the individual or from which the individual’s identity can be reasonably be ascertained;

Our commitment

We recognise that an individual’s right to keep personal information private is highly important. We are committed to protecting and maintaining the privacy, accuracy and security of personal information in accordance with the privacy principles established under the Act, specifically the Australian Privacy Principles (the Privacy Principles).

Your responsibilities

By engaging with us (whether in person, by telephone or in writing, including by electronic means), you agree:

to ensure that personal information provided to us is accurate, complete, up-to-date and not misleading and you acknowledge that we will rely on this information to conduct our business with you;

to notify us, in writing, of changes to personal information provided to us as soon as reasonably practicable; and

to co-operate with us in addressing our respective privacy obligations, having regard to the nature of our business relationship with you.

You have the right to refuse to provide us with personal information. However, if you decide to do so, we may be unable to conduct business with you.

How we collect your personal information

We only collect personal information, by lawful and fair means, and only if such information is relevant to our business relationship with you.

The personal information we collect may typically include (as well as other information depending on the nature of our business relationship) your name, date of birth, contact details (such as address, telephone numbers, email addresses), next of kin or emergency contact details, bank details and, where applicable, information about tertiary education records, and history of any prior dealings with us.

We generally collect personal information directly from you (unless you otherwise provide your consent). The personal information we collect may be provided in forms or applications, or where you provide information to us over the telephone, in person or in writing (including by electronic means). If you contact us or engage with us by electronic means, we may also keep a record of that contact. We may collect personal information about you from third parties and will let you know if we do so.

If we receive personal information about you that we have not requested, and if we determine that we could not have lawfully collected that information under the privacy law if we had requested it, we will destroy or de-identify the information, if it is lawful and reasonable to do so.

How we use your personal information

We are committed not to use or disclose personal information that we have collected, other than in accordance with this policy and in the manner contemplated by the Privacy Principles. It is our policy to obtain your consent before we use your personal information for any other purpose.

We may use your personal information as follows, depending on the nature of our business relationship (as applicable):

in the ordinary course of conducting our business, such as to provide our goods and/or services to you or to engage you to provide goods and/or services for us or on our behalf, which includes keeping you informed of events, news publications and promotional offers;

perform general management, administration and reporting purposes, such as invoicing and account management, which may include referrals to a debt collection agency and/or a tenancy database in accordance with applicable legislation;

for purposes related to employment of personnel, including recruiting of personnel, and providing internal services to our staff;

to comply with legislative and regulatory requirements otherwise necessary to fulfil our legal obligations and for internal corporate governance purposes; and

for all other purposes related to and in connection with our business, including fulfilling our statutory obligations and contractual obligations to third parties, subject to your rights under this policy.

Marketing and promotional uses

We may use your personal information to provide you with information about our services or products or those provided by third parties, that we believe may be of interest to you. To that extent, we may provide your details to such third party organisations for specific marketing purposes.

We may wish to refer to you based on the nature of our business relationship when marketing our business. We will only do so with your prior consent and will only disclose personal information to the extent to which you have consented.

You may opt out at any time if you do not wish to, or no longer wish to, receive marketing promotional information. To do so, you may contact us (in writing) and request that we no longer send promotional materials to you or disclose your information to other organisations for specific marketing purposes, or, where applicable, by clicking the “unsubscribe” button from promotional messages.

Whom we may disclose your personal information to

We may disclose your personal information (depending on the nature of our business relationship, as applicable):

to the Owner;

to any company which is a related body corporate or a related entity of us or the Owner or otherwise for corporate governance purposes;

to the tertiary institution you attend;

to your parent(s), legal guardian(s) or nominated emergency contact;

to debt collection agencies and/or tenancy databases, where you have not complied with your payment obligations, subject to applicable legislation;

unless you have asked us not to, to select organisations with whom we deal in connection with our business operations and which, in our assessment, may offer services or products to you, which may be of interest to you;

to government or regulatory authorities, law enforcement bodies, tribunals and courts where required or permitted by law;

to emergency service providers (such as paramedics or fire fighters) for purposes relating to your health, medical emergencies or in circumstances where we have serious concerns for your health, safety or personal well-being;

in circumstances required to protect our rights and property, or to protect the rights, property and personal safety of a member of the public, our staff, customers, clients or contractors; and

in circumstances where some or all of our assets or operations are or may be transferred to another party as part of the sale of some or all of our business.

Where it is necessary for us to give external third parties, such as contractors or consultants, access to personal information held by us, we take all reasonable steps to ensure that they are bound by confidentiality and privacy obligations with respect to the protection of your personal information.

Sensitive information

For the purposes of this policy, “sensitive information” is:

personal information, which is also information or an opinion about an individual’s racial or ethnic origins, political opinions or association membership, religious beliefs or affiliations, philosophical beliefs, sexual orientation or practices, criminal record; or

health, genetic or biometric information about the individual.

We only collect sensitive information (including health information) about you with your consent, except where we are required or permitted by law to collect your sensitive information without your consent.

We will only use your sensitive information where it is directly related to provision of our goods or services to you, and such reasonable secondary purpose. Specifically, we may use information relating to:

your racial or ethnic origin, religious beliefs or affiliations and your dietary requirements for the primary purpose for which we have collected such information (and any reasonable secondary purpose);

your health, for medical emergency purposes or in circumstances where we have serious concerns for your health, safety or personal well-being; and

Who we may disclose your sensitive information to

We will not share your personal sensitive information with any company or person other than:

the Owner;

any company which is a related body corporate or a related entity of us or the Owner;

the tertiary institution you attend;

your parent(s), guardian(s) or nominated emergency contact;

employees, agents or contractors of us, our related bodies corporate or related entities, or the Owner;

government or regulatory authorities (including law enforcement bodies, tribunals and courts), where required or permitted by law; and

any other person as permitted by law.

We take all reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations with respect to the protection of your personal sensitive information.

Storage of your personal information

Your personal information may be stored in paper-based form or electronically in our systems.

We maintain physical security over our paper-based and electronic data storage and premises and computer and network security, which are aligned with current industry standards to ensure that your personal information is kept secure and confidential. This includes implementing reasonable procedures to our information technology systems to protect personal information that is kept on our systems from misuse, interference and loss and unauthorised access, modification or disclosure. We will notify you of any breach of security which may result in unauthorised access to your personal information.

As a result of our global operations (with operations in Australia, New Zealand, the United Kingdom and USA), we may transfer personal information to those regional operations (i.e. outside Australia). We may also transfer personal information to our overseas operations or contractors to process, store or back-up personal information. Those recipients are generally located in New Zealand, the United Kingdom or the United States of America. Any such transfer, however, does not change any of our commitments to safeguard your personal information under this policy.

Where we no longer require your personal information (including where we are no longer required by law to keep records relating to you), we will ensure that it is destroyed or de-identified.

With your help, we will keep your personal information accurate, complete and up to date.

Privacy on our websites: cookies

In addition to personal information you may provide to us directly, we may also collect personal information from you when you access our websites via the cookies on our websites, to which this policy also applies.

A ‘cookie’ is a small text file which is placed on your internet browser and which we access each time you visit our website. The cookie allows us to obtain information about how our website is being used. Cookies may be used by us for various reasons, including remarketing across the internet through Google Adwords, maintaining website security, monitoring website traffic, measuring website performance and improving the navigational experience of our websites. We do not use cookies to identify you or any other user.

If you do not wish to receive cookies when using our websites, you should select the appropriate “opt-out” setting in your web browser.

Links on our website to other websites

Our website may contain links to third party websites that are not operated by us. We are not responsible for the privacy practices or policies of those sites and encourage you to review each website’s privacy policy and/or terms of use, especially if you intend to disclose any personal information via that site.

A link to any third party website is not an express or implied endorsement, promotion or warranty of the products or services offered by or accessible through that site or advertised on that site.

Accessing your personal information

You may request access to the personal information we hold about you by contacting us. We will respond to any such request within a reasonable time, subject to any applicable law.

If we cannot provide you with access, we will provide you with a written notice setting out the reasons for the refusal. For example, you may not access information relating to existing or anticipated legal proceedings between you and us, where the request for access is frivolous or vexatious, where access might threaten the privacy of others or where access would be unlawful or prejudicial to law enforcement.

Accuracy and correcting or updating your details

If you believe that personal information we hold about you is incorrect, incomplete or not current, you can request that we correct or update your personal information by contacting us in writing.

We will deal with your request within a reasonable time. If we do not agree with the corrections that you have requested, we are not obliged to alter your personal information accordingly. However, where we refuse to do so, we will give you a written notice setting out the reasons.

Questions and complaints

If you have any questions, concerns or complaints about or in connection with this policy (including any concerns about how we handle your personal information), please contact us in writing. We will respond to you as soon as possible.

If you are not satisfied with our response, please let us know and we will investigate further and work with you to resolve the matter.

Where we are not able to resolve the complaint with you, you may also refer the complaint to the Office of the Australian Information Commissioner.